China has signed Double Tax Agreements (“DTAs”) with more than 90 countries/jurisdictions since 1983. Over the past decades, the PRC tax authorities have issued a series of circulars which provide guidelines for technical issues. However, these guidelines only address certain articles of specific DTA’s.
On 26 July 2010, the State administration of Taxation (SAT) issued a
Circular Guo Shui Fa [2010] No.75, Article Commentary on China-Singapore Double Taxation Agreement and Protocols (“the Commentary”). For the first time, this set out SAT’s technical views, interpretation and practice guidelines for the implementation of a DTA. The Commentary provides detailed explanations on the basic concepts, introduces qualification criteria for non-residents seeking to claim tax treaty benefits and also gives some numerical examples for illustration. More importantly, the interpretations on the China-Singapore DTA and protocols also apply to the same article in DTAs concluded between China and other countries/jurisdictions.
Tracy Zhang will highlight the key points of the Commentary and their implications for non-resident enterprises and individuals, and provide insight for non-residents on tax planning opportunities. Yang Houlu will focus more on the capital gains tax of non-residents as well as the risks and opportunities of the application of tax treaties.
A breakfast will be served during the presentation.
Speakers
Tracy Zhang, KPMG
Tracy joined KPMG Beijing office in 1996. She was seconded to KPMG Qingdao office and functioned as the head of the local tax practice in 2006. From April 2007 till July 2008, she worked with International Corporate Tax practice in KPMG New York and Financial Service practice in KPMG London respectively.
Tracy is a PRC regulatory and tax expert on China investment related issues. Since 2004, she has been functioning as one of the leaders of the Financial Service tax team in KPMG Beijing, looking after domestic and foreign banks, funds and insurance clients. She has also been involved in developing structures for foreign investor’s investments into China, tax due diligences reviews in connection with M&A transactions and advising on cross border transactions.
Tracy’s major financial service clients include CITIC Bank, China Everbright Bank, Temasek, Swiss Re, Munich Re, and Zurich Financial Service.
Yang Houlu,
IBFD
Mr. Yang is a Business Development Manager and Senior Research Associate of IBFD (China). He is a member of International Fiscal Association (IFA) and was assigned as the IFA 2010 Country Reporter. Before he joined the IBFD, he worked as a tax advisor for the Beijing Office of Baker & McKenzie LLP, Rotterdam and Amsterdam office of Loyens & Loeff NV.
Mr. Yang holds a LLM in International Taxation from University of Leiden and a LLM from Peking University. He is the author of various articles published in highly-reputation journals and books, covering many areas of international taxation such as merger and acquisition, transfer pricing, service PE, capital gains tax, international tax planning and anti-abuse legislation.
Event Terms & Conditions
Please note that, though all are welcome to attend our events, we strongly recommend that you register online with us in advance so that we can keep you updated on any changes in the event schedule. From time to time, due to unforeseen circumstances we need to change the time or venue of an advertised event. So please do let us know by registering online if you plan to attend an event so that we can keep you informed.
To register for this event please register online by 6:00pm Thursday, 11th November. Please note that we will send you a registration confirmation. We require 24 hours notice for cancellations. For any further enquiries or registration, please contact us at tliang@euccc.com.cn.
Please note that registration starts at 8:00am and the seminar starts at 8.30am. Fees will be collected in cash at the entrance.
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